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Tax Planning › Offshore Funds › International Tax Issues

Allen Barron, Inc.

US Taxpayers and Expatriates May Need to File Offshore Disclosures and FBARs

Allen Barron, Inc. on

How many U.S. taxpayers and expatriates may need to file offshore disclosures and FBARs with the IRS? Should those who have not yet filed a disclosure application utilize the VDP (Voluntary Disclosure Program) or a...more

Allen Barron, Inc.

US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen

Allen Barron, Inc. on

In US Expatriate Tax Planning – Part 2, Ms. Allen picks up the conversation regarding tax and legal issue U.S. expatriates might face. The discussion turns to real estate matters, and the issue of moving money from the United...more

Freeman Law

Unreported Foreign Accounts? How to Choose the "Right" International Tax Attorney to Help You

Freeman Law on

If you have unreported foreign accounts, you are not alone.  Every year, I speak with hundreds of clients with tax non-reporting issues (e.g., FBARs, Form 8938, Form 3520, Form 3520-A, etc.).  The good news:  the IRS offers...more

Freeman Law

Is My Foreign Retirement Account Subject to IRS Information Return Reporting (FBAR, 3520, etc.)?

Freeman Law on

United States citizens and residents[i] are subject to federal income tax on their worldwide income. For example, even if a United States citizen permanently relocates to a foreign country, he or she will generally continue...more

Miller Nash LLP

Today in Tax: Foreign Account Reporting Requirements and Divisive Tax-Free Reorganizations

Miller Nash LLP on

FBAR Noncompliance Leads to More Severe Penalties in the 5th Circuit Penalties for FBAR violations can be severe if applied on a per-account basis, as opposed to a per-form basis. However, a taxpayer with “reasonable cause”...more

Gray Reed

Non-Willful FBAR Penalties Will be Much Higher in the Fifth Circuit

Gray Reed on

On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more

Freeman Law

The FBAR (Report of Foreign Bank and Financial Accounts): Everything You Need to Know

Freeman Law on

What is the Report of Foreign Bank and Financial Accounts (FBAR)? Congress enacted the statutory basis for the requirement to report foreign bank and financial accounts in 1970 as part of the “Currency and Foreign...more

Conyers

The DITC Issues Timely Compliance Reminders

Conyers on

The Cayman Islands Department for International Tax Cooperation (DITC) recently issued reminders to industry of compliance obligations in accordance with Common Reporting Standard (CRS) requirements and for the purposes of...more

Freeman Law

Death Doesn’t Stop the IRS—Failure to File FBARs

Freeman Law on

Benjamin Franklin once famously wrote in a 1789 letter, “In this world nothing can be said to be certain, except death and taxes.” Many recognize the truth in Mr. Franklin’s statement. Some may also believe that certain death...more

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